Scottish Guest Law Review: A Matter of Independence

I am delighted to host two very thoughtful blog posts from Scots lawyers on the issue of Independence for Scotland. I have, with their permission, taken their published posts from their blogs and hosted them here. Given the fact that we are, for the present, a United Kingdom, I thought these would be thought provoking. Love and Garbage and Lallands Peat Worrier are serious law bloggers who, it has to be said, also enjoy twitter – which is how and why I ‘met’ them.

Conjuring tricks, legislative competence, and referenda

As a child I was taken to a magic show, where the conjurer practised close-up magic. He’d wave the cards in front of you, and wonder of wonders you’d miss the sleight of hand. Until he tried it with a small boy who saw that the conjurer held two cards together pretending they were one.

What does that have to do with politics, though?

Well, a little while ago I noted how ignorant certain journalists were on matters relating to human rights – meaning that the incoherent Conservative policy escaped scrutiny during the election campaign. Scottish journalists are not exempt from similar criticisms. Too often the framework within which the Scottish Parliament operates is ignored when the political dimension of the Parliament is considered. The ignoral is a mistake. Smoke, mirrors, bluster, and crashes and bangs are classic distraction techniques – designed to draw attention away from the real position. Journalists and those scrutising our politicians should try not to be distracted.

The Scottish Parliament was not born free. It is a statutory creation, its powers circumscribed by the legislation establishing it. The Parliament, and the Scottish government (the executive within the terms of the Scotland Act 1998) can only act in accordance with the powers conferred upon it by the Scotland Act 1998. This was apparent before the Parliament was established. The restriction confirmed by the courts in Whaley v Lord Watson 2000 (later confirmed by the House of lords).

But the restrictions on the Parliament are sometimes forgotten (caught up sometimes in confusion between and conflation of the Westminster and Holyrood legislatures – Westminster notionally being the beneficiary of a doctrine of parliamentary supremacy (an English concept the Scottish courts reject as an absolute). And this means that pledges and promises made by Scottish parties in Scottish campaigns are therefore questioned only on a political basis without adequate scrutiny of whether a proposal can actually be implemented.

Consider for example a saga that began 3 years ago. In August 2007 the Scottish government issued the white paper that formed the centrepiece of the “national conversation”. This white paper proposed the holding of a referendum on scottish independence and included a draft bill to that effect. The period since then has seen much consultation, more detailed bills (pursuing the same central objective) – but the legislation has not been forthcoming.

Three years ago I suggested that legally (within the context of the Scottish parliament) the national conversation was hanging on a shoogly peg. I noted the following,

“ The powers of the Executive and Scottish Parliament are determined by the Scotland ACt 1998. This ACt provides that any bill which is put forward must be compliant with the scheme of devolution. If a bill is not on a devolved topic then it cannot enter the Parliament, never mind be passed. The 1998 Act provides that this is considered at at least two stages – first, the Presiding officer can prevent the bill entering the Parliament at all (a rule already exercised – probably inaccurately – when a bill which attempted to prevent the right of appeal to the House of Lords in civil court cases was rejected); second, the Advocate General (a UK government law officer) can – if a bill is passed by the Parliament – judicially challenge it before royal assent is given.”

And suggested that,

“The presiding officer is unlikely to give approval to the bill (given the precedent of rejecting a previous bill deemed to have constitutional import). ”

I suggested that the white paper engaged in elaborate sophistry as the legal problems inherent in the constitutional settlement were ignored, or downplayed with qualifying words.

While there has been toing and froing on the referendum I have been waiting for the inevitable. My view was that no bill would be introduced into the Parliament because a bill on the topic cannot fall within the legislative competence of the Scottish parliament. I expressed this view in blog comments in various places on the net (eg here). Imagine my astonishment yesterday then when the Sunday herald broke an exclusive story indicating that the referendum was being shelved.

“SNP sources also said the First Minister revealed there were legal problems surrounding the wording of the referendum question.

This related to talks between the Government and the Parliament’s Presiding Officer, who has to rule whether a Bill falls within the powers of Holyrood.”

This is no surprise, but will form the focus of this post as it has been ignored elsewhere.

During a previous session of the Scottish Parliament SNP MSP Bryan Adam proposed a Civil Appeals (Scotland) Bill which would have abolished the right of appeal from Inner House of the Court of Session to the House of Lords. The presiding officer (on his legal advice) ruled the bill fell outwith the competence of the Parliament. The justification was that the bill would have had an impact on the general constitutional reservation found in Schedule 5 to the Scotland Act 1998. If something which proposed to regulate an aspect of the legal system (against the context of the general devolution of matters relating to the courts, court procedure, and private law) is outwith the competence of the Parliament – then a bill which is about entering negotiations for the establishment an independent nation with its own legal system and legislature (or the break up of the United Kingdom, depending on your political preference) seems bound to have an impact on the United Kingdom Parliament (one of the matters on which legislation is expressly reserved to Westminster and on which the Scottish Parliament has no competence) and accordingly it would seem likely to be ruled by the presiding officer’s legal advisers as falling outwith the legislative competence of Holyrood.

I think that establishing that a bill on a purely constitutional matter falls within the legislative competence of the Scottish Parliament will be a difficult task. Schedule 5 of the Scotland Act seems pretty clear.

However, I was somewhat surprised today to read a post from the excellent Joan McAlpine that suggested that matters could be dealt with without a bill. Dr Matt Qvortrup – a senior lecturer in international relations and “ described by the BBC as the “world’s leading expert on referendums”” had written an article for the Herald during the summer. Dr Qvortrup wrote what, to a lawyer interested in the constitutional position, is a startling piece.

He opined,

“The referendum can be held after a so-called Order in Council, or by a Scottish Statutory Instrument (SSI). That is to say, the First Minister can decide to simply use his executive powers to have a consultation.”

Joan McAlpine, relying on the article, writes,

“Politically, such a move could put the Holyrood unionist opposition and the coalition Westminster government in a very tricky situation. If this consultative exercise included a devo max option alongside full independence, the outcome would certainly be a majority of Scots opting for radical change. That would put the SNP in a powerful position going into the 2011 election and, afterwards, if they formed a government. Whatever happened, the flawed Calman proposals would be holed below the water.

I am aware that this a sharp-intake-of-breath suggestion. The opposition could sink it with a no confidence vote. Would they dare? If they did, the issues at stake would be made very clear indeed. It should at least be examined.”

Dr Qvortrup’s proposition is startling to a lawyer because it is flawed in two fundamental respects.

First, Orders in Council or statutory instruments are examples of delegated legislation. The right to grant executive orders is (as are the powers of the Scottish Parliament itself) circumscribed. There are no general rights to legislate as an executive wishes. A government minister cannot decide that I would like to pass laws which require people to do X. A power so to legislate is required. A quick look at the Scottish statutory instruments demonstrates this. Each narrates the power under which the statutory instrument is made. Delegated legislation then involves the delegation of a power to legislate to the executive and any subordinate legislation (such as an Order in Council or statutory instrument) which is laid by the Scottish government has to be laid in the exercise of a legal power delegated to the government. I can find no legal power to hold referenda delegated to Scottish ministers. None is referred to in the leading modern Scottish texts on constitutional law. Additionally, I have trawled material from pre-devolution (where certain powers delegated to ministers are now delegated to Scottish ministers); have examined material in Scottish and British writings on constitutional law to determine if there would be such a power delegated under prerorgative powers (I can find no such power); and have looked at post-devolution legislation from the Scottish Parliament and Westminster and can find no such power. If there is no such power delegated there can be no Order in Council or statutory instrument. I accept that such a trawl will not have been exhaustive. However, this leads to the second flaw in Dr Qvortrup’s position.

Delegated legislation is not automatically waved through. Just because a minister says something does not mean that it becomes the law. The procedure for consideration of delegated legislation is set out in rule 10 of the Standing orders of the Scottish Parliament. Delegated legislation either requires affirmative procedure (meaning it requires the approval of the Parliament) or if it is not subject to affirmative procedure can be annulled.

Let us assume that contrary to my researches Dr Qvortrup is right and a power to legislate to hold a referendum has been delegated to Scottish ministers. Let us assume as well that this fictitious power does not provide that any statutory instrument or Order in Council has to be approved affirmatively. Dr Qvortrup bizarrely suggests that

“In Scotland’s case, the only option open to the Opposition would be to table a motion of no confidence in the administration.”

Sadly for Dr Qvortrup this is palpable nonsense. The position is set out in rule 10.5 of the standing orders:

“1. In the case of any draft instrument laid before the Parliament where the instrument may be made without the approval of the Parliament, any member (whether or not a member of the lead committee) may, no later than 40 days after the draft instrument is laid, by motion propose to the lead committee that the committee recommend that the instrument be not made (or, in the case of a draft Order in Council, be not submitted to Her Majesty in Council).”

This is not a motion of confidence in the government (with all of the implications involved therewith). This is simply a motion to annul (or a negative resolution) which would be dealt with and may be voted on in the normal way. Any member could make such a motion – from the humblest backbencher.

The political implications of holding a referendum are also considered by Dr Qvortrup. But until he – or one of those advocating the circumventing of Parliament by executive power – can point to a power that would entitle the Scottish government to lay delegated legislation and do this – and which would circumvent rule 10 of the standing orders, I suggest that no referendum can competently be approved by the Scottish Parliament.

The central plank of the SNP manifesto then will be a policy they cannot implement within the confines of the Parliament they are running for (although of course politically, an SNP majority vote would make any demand for such a referendum to be passed by Westminster politically impossible to resist).

Edited on 7th Sept at 4.45 pm to note the excellent response from Lallands Peat Worrier on the legality of the referendum bill. I disagree, but I think it is important that the argument is heard and engaged with by both sides. The failure of both sides to do so thus far (and journalists to scrutinise) says much about our system.

Before the 2010 Westminster general election, I tore rather mercilessly into the legal illiteracy at the heart of Tory pre-election pledges on the Human Rights Act and the European Convention. “And why beholdest thou the mote that is in thy brother’s eye, but considerest not the beam that is in thine own eye?” asks Scottish legal blogger Love and Garbage in an important post suggesting that is the SNP’s proposed referendum on independence demonstrates our own illiterate grasp of the legal constraints of the devolution settlement. Either that or a wilful blindness which would hardly be more laudable. The public orthodoxy assumes that Holyrood is perfectly empowered to hold such a referendum. Even the opposition parties believe so. How else could Wendy Alexander have cried “bring it on”? The question then becomes a matter of pure politics, whether such a referendum should be held a question finally to be answered by the institutional majority. “Unionists have killed off the independence vote”, suggested Salmond this morning. This, argues Love and Garbage, is so much Eckly razzmatazz:

“The central plank of the SNP manifesto then will be a policy they cannot implement within the confines of the Parliament they are running for (although of course politically, an SNP majority vote would make any demand for such a referendum to be passed by Westminster politically impossible to resist).”

Why not? His starting point is the legislative instrument that is the parliament’s foundation ~ the Scotland Act 1998. As he rightly stresses, it is something that the Scottish media and the rest of us often lose sight of, but Holyrood is not an assembly at liberty to do as it pleases. The Act is structured with general and specific reservations. At the top of the general list in Schedule 5, we find the Constitution. Section 29 provides that “An Act of the Scottish Parliament is not law so far as any provision of the Act is outside the legislative competence of the Parliament…” and that “A provision is outside that competence so far as … (b) it relates to reserved matters…”. So, how is the phrase “relates to a reserved matter” to be construed? The Act offers this guidance:

(3) For the purposes of this section, the question whether a provision of an Act of the Scottish Parliament relates to a reserved matter is to be determined, subject to subsection (4), by reference to the purpose of the provision, having regard (among other things) to its effect in all the circumstances.

“For example, the subject-matter of the Carriage of Goods by Sea Act 1992 is a reserved matter: para 1 and Section E3 of Part II of Schedule 5 to the 1998 Act. Obviously, therefore, if the Scottish Parliament purported to pass a Carriage of Goods by Sea (Scotland) Act with the sole purpose of repealing the 1992 Act in Scots law, its purpose would relate to a reserved matter and so its provisions would be outside the competence of the Parliament by virtue of section 29(2)(b). In practice, such a clear example would be unlikely to get past the legal advisers to the Scottish Parliament. In real life the problem is likely to arise in more complex situations.” [Para 75]

The legality of a referendum on independence is undoubtedly one of these more complex situations. To those whose consciousness hasn’t been rearranged and distorted by a legal education, what follows will undoubtedly seem like the worst sort of quibbling for which both the lawyer and the theologian are justly despised. I ask you to bear with me. In support of his thesis, Love & Garbage mentions the abortive Civil Appeals (Scotland) Bill, which the Presiding Officer of the day, George Reid, ruled to be outwith the competence of the Parliament on legal advice. That Bill was an affirmative legislative attempt to end the practice where Scottish civil appeals can escape from the final judgement of the Inner House of Court of Session by fleeing south to the House of Lords as was, now the United Kingdom Supreme Court. A sort of judicial repatriation, then. The Bill’s failure owed to the assessment that such a motion was beyond the competence of the parliament, under the constitutional reservations in Schedule 5 of the Scotland Act. Love and Garbage again ~

“If something which proposed to regulate an aspect of the legal system (against the context of the general devolution of matters relating to the courts, court procedure, and private law) is outwith the competence of the Parliament – then a bill which is about entering negotiations for the establishment an independent nation with its own legal system and legislature (or the break up of the United Kingdom, depending on your political preference) seems bound to have an impact on the United Kingdom Parliament (one of the matters on which legislation is expressly reserved to Westminster and on which the Scottish Parliament has no competence) and accordingly it would seem likely to be ruled by the presiding officer’s legal advisers as falling outwith the legislative competence of Holyrood.”

I propose that we can distinguish this precedent quite simply from referendum. Or at least, might be able to make a manful legal argument to that effect. Assume that George Reid was correct and that the proposed Bill was beyond Holyrood’s competence. What about a Bill attempting to have a referendum on the subject of the Civil Appeals Bill? Holyrood couldn’t delegate powers for the Scottish people to make binding resolutions in a referendum. What if the public were asked “Do you agree that the civil appeal to the House of Lords should end?” As I understand him, on Love and Garbage’s logic such a referendum is incompetently “tainted” by its reference to a clearly reserved subject. Couldn’t we think about this differently and harden this contrast between admittedly incompetent affirmative legislation and legislating to institute a referendum process for the expression of public opinion on some subject which happens to be reserved? As I understand him, Love and Garbage is entirely consistent on this level. If the proposed referendum on independence is incompetent, surely my imaginary referendum on the Civil Appeals bill would also fall to be rejected.

I’d propose an alternative interpretation (I should stress, in a spirit of advocacy rather than in any certainty that a court would uphold my argument) and submit that legislating to conduct an advisory referendum on both reserved subjects can be distinguished and need not incompetently “relate” to the constitution as a reserved matter. All of this hinges on whether conducting a referendum on a reserved matter of itself “relates” to a reserved matter under section 29 of the Scotland Act. “Relation” is obviously not being used here in its common-sense definition of any tenuous connection. The Act suggests that we attend to (a) the purpose and (b) the effect of the legislation. So what is the essential purpose of a referendum on independence? As Lord Rodger noted:

“Sometimes, of course, the purpose of a provision may be obscure. And, even when it is not obscure, people may describe the purpose in slightly different ways” [Para 113]

This seems to me to be at the heart of the argument. How should the essential purpose of the referendum be described? On one level, we might say that its primary purpose is to canvass the opinions of the Scottish people. In law, it would have no binding effect. No legislative modifications would necessarily follow. Indeed, its lawful effect would simply be to set in motion a consultative process. Ascertaining the opinion of the Scottish people on a particular question is not a reserved matter. L&G would no doubt contend that this is a rather artificial analysis and that effect should be given a more expansive definition. Moreover, it is no secret what the general purpose of the SNP is in bringing such a referendum forward. He might be right in both respects. However, such arguments emphasise an important point. Whatever one’s immediate view of the merits of either contention, it seems fair to say that the authoritative judicial definition of “relation to a reserved matter” remains opaque. Alan Trench, a far more dexterous public lawyer than I am, has recently composed this worthwhile piece on the wobbly line drawn between devolved and non-devolved powers of the parliament. My point is that the competence and legality of any referendum is at least arguable, if one begins to accept the separability thesis I outline above. That said, Love and Garbage is quite right to emphasise that blithely assuming Holyrood can competently legislate for a referendum is problematic. I have no insight into the SNP’s legal advice or their legal thinking. However, I suspect that this analysis might also go some way to explaining the reported difficulties which were experienced in composing suitable wording.

So here we have a political problem. There seem to me to be clear and reasonable dubieties about the legality of such a referendum. In reality, these are unlikely to be resolved any time soon. However, assume for the sake of argument that a court uphold’s Love & Garbage’s analysis and repels my own submissions. What the devil is the SNP to do? On one level, emphasising gaps between public expectations of devolution and its lawful reality makes the nationalist case. On another, the revelation that such a referendum is beyond Holyrood’s competence to command – and it has taken this long for such fact to surface – assails the integrity and competence of the party which proposed it. Surely you could have – should have – known, the press might well ask. It is also worth bearing in mind that public attitudes towards legal certainty may not be kind to the SNP in such circumstances. If you assume the law is a great book of obvious rules and strictures, a failure to notice legal impediments on such an important subject seems astonishing, despite the fact that nobody else seems to have noticed them either. Moreover, I shouldn’t like to play the seer if a challenge to a proposed referendum is eventually the test case which goes some way to clarify the relationship between reserved issues and devolved powers. That would be a case with astonishing political ramifications which would undoubtedly weigh with any court which heard argument on the subject. Indeed, it is hard to conceive of any other political issue in devolution which could prompt more controversy.

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“Parliamentary Sovereignty” is an English notion? Allow me to examine that a little.

The UK Parliament is based on a merger of the former Scottish Parliament and the former English parliament. It is far from clear whether, at the time of the merger under the Treaty of Union, either parliament regarded itself as “sovereign”. They certainly did not do so in any modern sense of that term. However, due to the outcome of the English civil war, the English parliament would have been perhaps more likely to regard itself as “sovereign” than the Scottish Parliament. It appears that the idea of parliamentary sovereignty – (enabling parliament to make or unmake any law whatever) – owes much more to the influential views of A.V. Dicey who, of course, lived long after the Union with Scotland.

The whole idea of parliametary sovereignty is challenged in the excellent and readable book by Richard Gordon QC “Repairing British Politics”. Gordon (who argues for a written constitution) sees parliamentary sovereignty as a power-sustaining device. No one has ever voted for parliamentary sovereignty and it lacks democratic foundation.

Turning to Scottish devolution. The “new” “1998 Act” Scottish parliament has limited powers. It cannot claim to be in any way “sovereign” and able to do whatever it wishes. Of course, the Scottish politicians, will try to disguise this for their own reasons. Nevertheless, the Labour government has put in train a situation which will lead to more and more power being devolved to Scotland and there will be growing demands for the fetters in the 1998 Act to be removed.

It is also interesting that, having set up a SUPREME COURT of the U.K., there are now proposals to limit the jurisdiction of that court further. One might have expected a supreme court to have been made the ultimate appellate body for all Scottish matters (including criminal) but things seem to be heading the opposite way.

A question which I have occasionally wondered about is whether the “old” (“pre Act of Union”) Scottish parliament was ever actually abolished? If not, the “new” Parliament might be a total interloper. Of course, whatever the legal theory, we know that it does not march alongside political reality (Blackburn v AG 1971).

Meanwhile, the Scots continue to enjoy their “no top up fees” university education and free care for the elderly. Good luck to them but it shows that we are far from being a “UNITED” Kingdom in the 21st century.

Obiter, I think you are right that it is not clear why the Scots should imagine that parliamentary sovereignty is an English concept as it is a nineteenth century development.

It refers to the notion of the Crown in Parliament and I had always thought that it was a description of the UK constitution as it had historically evolved, contrasted with states with a written constitution or those where there was an absolute monarch. As you say this was what happened in the English parliament in the seventeenth century after the Civil war and then in securing the protestant succession. From dim recollection the Scottish parliament went through a similar manoeuvre anyway, but the Scots will claim that the monarchy in Scotland had always represented a contract with the people. Nevertheless I will leave it to people who know more than I do to argue the case.

I think that even Dicey recognised the limits in respect of legislating for the Empire, and it is clearly a nonsense to say that the current UK Parliament is not bound by the legislation that gave dominion status/independence to Canada or Australia. (Then I am not a lawyer but did read history at university.)

However one looks at it, the idea of parliamentary sovereignty (or “supremacy”) means that we do, in fact, live in an elective dictatorship. The doctrine enables “the Queen in Parliament” to do whatever it likes. We have no “rights” save whatever the “Q in P” chooses to give us. It is argued that the doctrine would prevent the U.K. adopting a written constitution since the whole thing could be repealed anyway.

Let us look briefly at the political realities as opposed to the legal theory. The Queen must always give Royal Assent to any Bill which has passed through Parliament. Almost all the business of parliament is controlled by the executive and Ministers dominate most of the business. Hence, the idea of a “Q in P” having sovereignty becomes, in reality, the executive holding sovereignty. The whole concept is a power sustaining device and is non-democratic. In the hands of a Prime Minister with an enormous majority in the Commons, this is a truly scary concept.

Richard Gordon’s book – to which I referred above – considers this matter in some detail. However, I commend the book since it is eminently readable and it is not expensive.

My parliamentary sovereignty line was a throwaway but it is perhaps useful to give some Scottish context. The Diceyan analysis assumes that Parliament was born free and accordingly can legislate in any area (in theory – but of course subject to the practical limitations identified by Millar). The Scottish view (endorsed by the First division of the Court of Session in MacCormick v Lord Advocate 1953 SC 396 is that as the UK Parliament was a new body created on the union of 1707 it was born subject to fetters. Among those fetters are certain aspects of fundamental law which Westminster could not amend or repeal – including the preservation of the independence of the Scottish legal system and Scottish courts. This analysis was accepted by Lord Hope in Scottish litigation regarding the poll tax. This suggested (pre-Factortame) that Westminster primary legislation could be judicially reviewed by the Scottish courts and struck down. Given the controversy surrounding Factortame at the time of the decision it appeared that such an analysis was not accepted as generally possible in English law without European intervention (and indeed the HRA does not permit this remedy).

The perception perpetuated in the Scottish courts is that the Diceyan analysis is an English one. I merrily lifted that without sourcing.

[…] question of legislative competence from the Peat Worrier (which together with my original post was reprinted on Charon QC’s law blog for a wider UK legal audience) arguing with ingenuity and flair that Holyrood could so […]

As a mere mortal in the presence of such concentrated legal minds I am grateful for such interesting and erudite discourse on a matter. It is a subject which troubled me somewhat and it did move me to write early in July to the Presiding Officer to clarify for me whether matters relating to constitutional issues were reserved, whether the Scottish Parliament using parliamentary time and resources to consider such matters would be acting ultra vires, and whether as Presiding Officer he would have a duty to refuse to allocate parliamentary time to debate such matters. A week later his office said they would get back to me.

I subsequently received a reply from the Presiding Officer late July. He advised me that the constitution is a reserved matter . The parliament may debate issues regardless of whether devolved or not, however he had a duty under s31(2) Scotland Act to provide a statement on legislative competence of each Bill on its introduction. His statement must express a view one way or another on whether or not the Bill is or specified provisions of it are within the legislative competence of the Parliament. His statement however does not prevent the Bill from being introduced .

Would that be ratio or obiter? (See, i did stay awake so many moons ago in the compulsory law element of the intermediate marcel waving course.)

Tangential question relating to an earlier comment regarding the Supreme Court. I seem to remember that Scottish Civil cases were appealed to the Lords as a result of a particular case Green??. Given that the Lords is no longer a court of appeal and presumably we have legislated to impose the new Supreme Court onto the Scottish Civil system, is this not contrary to the guarantees in the Treaty of Union?

Very many thanks to deebel for the fascinating comment – going right to the Presiding Officer. This mirrors the Civil Appeals process – which on the declaration was then voted down (on that basis).

The Appeal to the Lords was not in the Treaty of Union. It was a power the Lords took for itself. the Union provisions provide English courts cannot decide matters on Scots law and preserve the independence of the legal system. The Supreme Court does not impact on either of these (and indeed its location arose in part from observations Lord Hope made during the debates to ensure it was not merely housed with the English court of appeal and high court – to ensure that it was 1707 compliant).

Thanks loveandgarbage for clarifying the Appeals to the Lords query. I was looking at the matter from the perspective that as the ultimate appeal to the Lords came into being post- Treaty of Union and that the Lords were removing themselves from the process, would the final civil appeal not simply revert to the Court of Session? I wondered, given that the Lords heard civil appeals as a consequence of a sort of “land grab” from the Court of Session, why there was competence to legislate a Supreme level onto the Scottish Civil process at all given the Treaty of Union?

Thanks for all your comments on our Scots blawgs and to our learned host for accommodating them here. I was a little concerned that our “damned Scotch metaphysics” might chase you away but devolution ought to be cat nip for constitutional enthusiasts and a welcome change of pace from the unrelentingly priapism of Diceyan parliamentary sovereignty. I read debeel’s remarks with particular interest.

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